This will be a boring post if you aren’t interested in product labeling… I continue to plow ahead with the label design. Above is the latest with small tweaks here and there. Turns out we’ll save 5¢/lb in processing costs if the Safe Handling Instructions are included on the label so that is back. This is because it saves the butcher time and labels.
I’m still working my way through reading all of the USDA regulations on labels that I can find. Very interesting stuff. With the deep snows we got today I figured it was a good time to do some reading. See:
- Label Application Form – Fill this out to submit an application.
- Label Application Q&A; – Read this to get started
- Laber Submission Checklist – 1, 2, 3… approval one hopes.
- USDA Labeling Guidance – This is a good starting place to start exploring.
- Labeling 101 Presentation – Includes check lists of required items, allowable generic modifications, etc. Fast overview.
- Labeling Policy Book – The reference list of terminology. What everything means in the USDA labeling glossary.
- Meat Labeling Terms – Basic terminology definitions.
- Labeling Policies – Another jumping off point to docs.
- Animal Production Claims – What do various claims mean according to the USDA definitions.
- Claims Guidance – How to backup claims for the label, adding required disclaimers, etc.
- Basics of Labeling
- Safe Handling Instructions Directive – Info about the Safe Handling Panel with Q&A.;
- Safe Handling Text – More info on this panel.
- Generic Labeling Info – Not what I’m doing but if you make a label with just the basic info it is easier and here’s the doc on it. This also discusses what changes can be made to a previously approved label without going through re-approval.
- Very Small Plant Outreach & Letter – Help for the little guys.
- FSIS Label – Info from American Association of Meat Processors web site on labels. Lots of additional links to explore.
- Ham – Interesting fact sheet all about different types of hams and how they are made.
I am getting my materials ready to submit to the USDA for getting the label approved. They say it is about two weeks from submission to approval in most cases. An label expediter like Prime Label Consultants in Washington, DC is $20. It isn’t clear to me what I’m getting for that $20.
I’ve gotten quotes from several printers. The current best bid is from Growers Discount Labels who also happens to be the printer for Certified Naturally Grown so I’ve see what their labels look like and am pleased with them. They come well recommended from a reader.
Unfortunately I must print labels for each of the two butchers we use as the establishment number must be printed on the label. I’m not happy about that. I would be very interested to know who came up with this brilliant little idea:
Remember that you are dealing with a producer, farmer, and feedlot operator as opposed to plant management. They need to understand that the label is approved for use at a particular federally inspected establishment [slaughter house]. It does not belong to the producer of the animals. If he changes establishments in the future, he must seek a new label approval.
–USDA Claims Document
What that does is lock a small farmer into a particular slaughter house and force them to go through the USDA’s hoop jumping every time they want to use a new slaughter house and get new labels printed for each and every slaughter house. This is unnecessary. Why was this rule created? Well, let’s look at who benefits – it almost sounds like a nursery rhyme:
- The Butcher – Slaughter houses benefit because they lock small farmers into using them since they can’t easily switch to another slaughter house without going through the whole label re-approval and reprinting process which is damn expensive and time consuming.
- The Banker – More money changes hands, the economy gets stimulated, churns and they take their little tithe.
- The Printer – They get to print more runs of labels.
- The Rulemaker – USDA bureaucrats benefit because it gives them more jobs.
That’s four groups and I’ll bet that at least two of the four were involved in making this rule so it is a conspiracy by definition… It would be fascinating to know how this came about. I doubt we’ll ever truly know.
This hurts small farmers because it increases their costs and limits their options. This rule hurts the environment because it means more labels will be printed and wasted. This hurts consumers because it drives up food prices by increasing the cost of production. This rule hurts my sense of fair play. Bad, bad, bad, bad…
Just for the record, the USDA is incorrect about the ownership of the labels. I design them, I print them or pay for the printing, I own them. That’s copyright law and basic property ownership law. The bureaucrats can’t do a taking without Eminent Domain proceedings. That’s the Constitution, the Bill of Rights, and not just a piece of paper. The USDA’s bureaucratic regulations can’t actually change that no matter how much they may like to believe so. Note that I’m speaking as a lawyer which I play in an alternate universe where reason, honesty and decency rule. :) I am not a lawyer in this universe nor do I play one in the movies.
It is also interesting to note this policy statement:
Non-Retaliation Policy All FSIS personnel, particularly those who make regulatory and enforcement decisions, are not to retaliate in any way against establishment owners, operators, or employees who have questioned or appealed regulatory or enforcement decisions. FSIS personnel who have engaged in retaliatory behavior may be subject to disciplinary action. (See also FSIS Direct
ive 4735.7, PDF Only) –USDA Policy Statement
Which all brings me to this bit of regulations:
(i) The official establishment number of the official establishment in which the product was processed under inspection shall be placed as follows:
(1) Within the official inspection legend in the form required by part 312 of this subchapter; or
(2) Outside the official inspection legend elsewhere on the exterior of the container or its labeling, e.g., the lid of a can, if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition and accompanied by the prefix “EST”; or
(3) Off the exterior of the container, e.g., on a metal clip used to close casings or bags, or on the back of a paper label of a canned product, or on other packaging or labeling material in the container, e.g., on aluminum pans and trays placed within containers, when a statement of its location is printed contiguous to the official inspection legend, such as “EST. No. on Metal Clip” or “Est. No. on Pan”, if shown in a prominent and legible manner in a size sufficient to insure easy visibility and recognition; or
(4) On an insert label placed under a transparent covering if clearly visible and legible and accompanied by the prefix “EST”.
So, I’m trying to decipher that to see if it will let me print the meat label without the Est. Number so that the Est. Number can then be printed when the weight and cut are printed or hand stamped. I have a call in to the FSIS at the USDA. Details to follow. There is an intriguing reference to a “Dual Legend” which I am trying to track down into the regulations.
Why am I nagging at this task so? Well, because it appears that once I set the label in stone, er, USDA approval, it will be a pain to change anything. Thus it is very important to get everything right. Additionally I want to get it approved in the first go around rather than getting it rejected and bounced back to me which will add more time and expense. I’m learning all sorts of interesting things in the process so it is time well spent.
If you’re interested, also see these older posts: Meat Label and Business Card Post and the Label Wall at the butcher’s place. Also see tomorrow’s post about the LX-400 label printing machine.
“You don’t have to be nuts to see conspiracies in the government. Just read through their documents for a while…” -WJ
Friday:
Outdoors: 18°F/7°F Overcast, 2″ Snow
Farm House: 59°F/50°F two logs
Tiny Cottage: 54°F/46°F
Saturday:
Outdoors: 21°F/17°F Overcast, 23″ Snow
Farm House: 60°F/49°F four logs
Tiny Cottage: 53°F/44°F
Walter Jeffries Tinker, Tailor… A bit eclectic & a tad eccentric, polymath, quantum mechanic & Farmer. Also lucky at cards.
Like your label. Colorful and stands out. Not to cluttered with the pig “open” and without print. Nice job. Good luck—hope you don’t run into the roll of red tape.
Monica
Wow. In my universe government exists solely to maintain open pathways for opportunity. *sigh*
Not to rub it in (i’m sure you’re still grateful for your outdoor-freezer anyway), but we enjoyed a BBQ outdoors at my in-laws… the bank clock across the street read 77 degrees at 4 pm! We’re a tad south of the halfway point between the north pole and the equator. Sadly, some mosquitos were out, here at our place, and West Nile was a severe problem around here last year.
Printing without the est. number seems like a good idea. A friend of mine is on her third label printing after two slaughter houses burnt down in New England. She’s probably not the only one either.
it seems that there is a perfect opportunity for the butcher to include the establishment number when they print the weight. surly that changes per label but might be tooled to include that little snippet?
thanks for sharing your trials and tribulations with uor Uncle Sam,it helps remind me why Ill never sell more than 1 1/2 pigs as meat and thats to friends!! Did you ever hear of people getting sick eating meat from small producers? I havent. I have a catalog from brownCor.com where you can buy blank labels and print themon your laser jet they run between 15 and 21 buck per 100 cheaper if you buy quanity
Walter,
I’ve been reading your blog for a while now and I think it’s great. Quite an inspiration for an aspiring small-scale farmer (me).
I do have one comment about your label. I think it is too cluttered with wording. Especially the part about “Grass-Fed Humanely Free-Ranged Farm Raised Outdoors”. That’s a bit of a run-on sentence fragment and you’ve already said it’s pastured pork and naturally grown. I think simpler would be better. In fact I think you can get away with just the “Naturally Grown” and “Buy Fresh/Local” and leave out the words on the pigs back and below the pig.
My wife is a graphic designer and I find these things are very subjective so you can of course totally ignore my advise. I do think that simple designs stand out better.
Chris
Karl, that was my thought too. The Est. 8844 or what ever could be simply printed along with the weight. The butcher is very resistant to this idea. I think he really wants to lock me in to him with the labels. We don’t have so many butchers around that I can simply use others. The two I want to use are in different areas – my thought is to be able to better serve each area. Both are almost exactly one hour from us, none closer. But, there may be a better solution – See tomorrow’s post…
Walter,
Help me understand. Are you going through the USDA labeling process because you have to, or want to in order to be able to better market your meats?
Is this a condition to sell meat as individual cuts to a retail market or restaurant or does all meat in VT get treated the same?
Here in WA, in my area, we have three options open local farmers. 1) Cart animals to a slaughterhouse 400 miles away for USDA approved slaughter and the right to market individual cuts to consumers, stores and restaurants. No extra labeling required unless you wish to single out your wares. This is, apart from the mileage, stress to livestock and hassle to farmer, the least expensive and most expedient route.
2)There is a mobile USDA slaughter trailer which costs per hour, has a set-up fee, comes with a USDA inspector to your farm. In it is a complete, sanitary slaughter rig. The biggest complaint apart from the expense of it is how slooooow the process is. We all know you can take an animal from live to carcass in about 30 minutes if you have to. In the USDA trailer it takes on average 2 hours for one fella to get a steer, or hog, from live to hanging sides. Time the farmer is paying for. In addition, everything is carted away for cutting and wrapping–for which the USDA facility associated with the mobile unit charges another premium. It is so rigid, you can’t get offal–heart, liver, kidneys, trotters, tails, heads–that you aren’t selling but want for personal consumption–they are all wrapped and frozen, at your expense, with everything else.
This unit has opened up new arenas for local farmers to be able to process and sell their meats to restaurants, farmers markets, grocery stores and direct to customers on a per-cut basis, but the time and cost has cause the whole thing to be rejected by many.
The third and final option 3) we almost all do is custom-meats. Butcher comes to the farm slaughters live animals and in the last instance–4 sheep, 1 bull, 1 4 year cow, 1 heifer, 2 hogs–are all hanging carcasses 3 hours later. Offal can be collected as desired, rumen can be composted. The sides are taken away for cutting and wrapping–with hanging in the case of the beef (but not, unfortunately, the lamb and mutton). The meat is pre-sold on the hoof by the whole, half or quarter. Each customer contacts the butcher with how they want their meat cut and collects it when its ready–or in our case we get it for them when we pick up our un-cut sides (like to age our grassfed beef for more than 14 days. . .) and have a day of distribution when we return home. Everything is wrapped and frozen, and almost like it was bought at the store, but oh so much better. . . .
The odd and annoying drawback to this method is that this meat can only be consumed by the person who bought the whole, half or quarter live (and obviously the farmer) and cannot be served to the public or sold at a market, grocer or restaurant–not that that has stopped anyone. . . .Often times the butcher has his own herd and sell animals the same way.
I’d like to see a fourth option–Farmer hires a butcher to come to the farm and together the dispatch and process the animals on the farm at a simple, yet sanitary on-farm processing room. The additional money kept by the farmer would pay for the facility, walk-in refrigerator and freezer and direct farm-shop sales. The customers could sign a waiver or contract or ? to accept that this meat is no different than meat cut at the custom-butcher facility and understand that it is at their own risk they enjoy the deliciousness of local, fresh meats. Perhaps this happens in a parallel universe. . . .
Podchef, I tried to avoid doing the USDA approval process, or at least put it off, but in Vermont there is only one state inspected butcher/slaughter facility. All the others are USDA and state. If they are both then the USDA supercedes and we must get USDA label approval IF we make a claim on the label. A claim can be:
Geographic (Locally produced, Vermont)
Production (grass fed)
Health (High in Omega-3 Fatty Acids)
Negative (No antibiotics fed)
etc.
I was not interested in making a label that had no claims. The state of Vermont approved it with the claims I have BUT the one and only state only slaughter facility is too far away for us to use. So I have to use the USDA inspected facilities and thus must get their approval for the label.
Sooo…. I’m learning all about the process. :) It is interesting. I would even say that going through the process has improved the label since as I read through all the regulations I gain insights.
A big advantage of having the USDA approved label and inspection is that it means we’ll be able to sell out of state. One of the places that wants to buy is in New York City. Another is in New Hampshire. Both have no supply of local pork or even New England pork never mind pastured pork.
Thank you for you info about your local mobile slaughter unit! There is much discussion going on in Vermont about this right now and I have forwarded your insights to the MEAT@LIST.UVM.EDU list.
Personally I think your option #3, the on-farm slaughter, is by far the best for all the reasons you gave and more. That is what I would like to be doing for our direct customers. But the state of Vermont currently bans us from this. One must have actually raised the animal to be allowed to do this. It is absurd and overly restrictive. We are pushing to change that.